Russian Supreme Court Rules on Treatment of Income as Other Income under a Tax Treaty

The Russian Supreme Court issued Decision 302-ES20-7898 on 6 October 2020 regarding the treatment of income as within the scope of the "Other Income" article of a tax treaty.

The case involved a Russian company, Coiltubing-Service LLC, which had entered into a financial leasing agreement with a company in Belarus, ASB Leasing LLC. In making payments to ASB Leasing, Coiltubing considered that the payments fell within the scope of Article 7 (Business Profits) of the 1995 Belarus-Russia tax tr…